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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Reclassification of own funds instruments from a grandfathered category to a fully eligible category and purpose of grandfathering provisions

Is it permissible for an institution, and if so under which circumstances and/or criteria, to reclassify own funds instruments from a grandfathered category to a fully eligible category in particular in a context where no change in the relevant applicable laws or terms and conditions of the reclassified instruments has taken place before the reclassification? Would the answer be the same for a reclassification of own funds instruments from a disqualified category to a fully eligible category?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4417
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/12/2018

Operation and security risk assessment of a branch of a credit institution

Does a branch of an EU credit institution operating in another Member State have to prepare separate assessment for its payment related activity and if yes which competent authority shall be responsible for receiving the assessment - is it the competent authority of the host or the home Member State?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/04 – Guidelines on ICT and security risk management - repealing EBA/GL/2017/17
  • ID: 2018_4176
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Applicability of exemption from strong customer authentication (SCA) under Article 17 for card payments

Is Article 17 of Regulation (EU) 2018/389 applicable for the payer’s Payment service provider (PSP) for card-based payments?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4239
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Interpretation of 'Active request for account information'

How should 'active request for account information' by a Payment Service User (PSU) be interpreted the wording of article 36(5)(a)(b) of the RTS SCA?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4172
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Major incidents reporting

Must Payment Service Providers (PSPs) submit major incident reports to their home National Competent Authority (NCA) when the cause of the major incident is outside the control of the PSP and when updates on the major incident are dependent on information provided by a third party?Where there is consolidated reporting of an incident to the EBA/ECB in the context of, for example, card payments schemes, is reporting of the major incident by PSPs to their NCA under PSD2 required?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/03 - Guidelines on major incident reporting under PSD2 - repealing EBA/GL/2017/10
  • ID: 2018_4144
  • Topic: Major incidents reporting
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Applicability of Strong Customer Authentication (SCA) to existing recurring payments solutions

Is Strong Customer Authentication (SCA) required if the series of recurring transactions was initiated before the date of application of the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4048
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Reporting of financial asset sales and write-offs in FINREP template F 02.00

How should financial asset (e.g. loan portfolio) sales and write-offs be reported in the template F 02.00 (Statement of profit or loss)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2018_3716
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/12/2018

Criteria for the application of the transaction risk analysis (TRA) exemption – Fraud rate calculation methodology for the application of the TRA exemption

Should ‘friendly’ frauds be included in the “total value of unauthorised or fraudulent remote transactions” considered for the calculation of the fraud rates for the application of the TRA exemption?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4032
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/12/2018

Deferral of variable remuneration in instruments

Does a credit institution have the obligation to hold the instruments (as shares, for example) during the deferral period of variable remuneration in instruments?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2018_3815
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 23/11/2018

Treatment of a securities lending and borrowing service with regard to the LCR / Traitement d’un service de prêt et d’emprunt de titres en ce qui concerne le ratio de couverture des besoins de liquidité

What is the treatment of a securities lending and borrowing service with regard to the LCR?***FR:Quel est le traitement accordé au ratio de couverture des besoins de liquidité pour un service de prêt et d’emprunt de titres?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2015_1962
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 09/11/2018

FINREP. Validation rule v5468_m

Is validaton rule v5468_m correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2018_3884
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

C 08.01 - validation rule v5739_h (applicable as of v2.7)

According to validation rule v5739_h, the value in row 010 (“Total exposures”) should be >= the value in row 015 (“Exposures subject to SME-supporting factor”). We think this rule is only relevant for columns which report amounts and not for columns which report averages, such as column 250 (exposure-weighted average maturity value). Can this validation rule be corrected and not be applied to column 250 anymore?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2018_3774
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Reporting of memorandum items behavioural outflow/inflow in the ALMM maturity ladder (C 66.01)

The instructions on memorandum items behavioural outflow/inflow state to redistribute the amounts in items 1.3 (deposits) and 2.2 (loans). Does this mean that the total amount of notional and interest cash flows according to contractual agreements are redistributed across the time buckets? In other words, is it expected that the total amount in column 020 till 220 of row 17 (and 18) equal the total amount in column 020 till 220 of row 1.3 (and 2.2)? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2018_3763
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

IFRS 9, validation rule v1386_m

Validation v1386_m for IFRS 9 (taxonomy 2.7) seems to be incorrect. {F 43.00, r070, c050} + {F 43.00, r070, c055} = xsum({F 20.05.b, c030, (r010-030, sNNN)}) Template 43 shall include reconciliation between the carrying amount of the item ‘Provisions’ at the beginning and end of the period by the nature of the movements, except provisions measured under IFRS 9 that shall instead be reported in template 12. In template 20.5, ‘Provisions for commitments and guarantees given’ shall include provisions measured under IAS 37, the credit losses of financial guarantees treated as insurance contracts under IFRS 4, and the provisions on loan commitments and financial guarantees under the impairment requirements of IFRS 9 and provisions for commitments and guarantees under national GAAP based on BAD in accordance with paragraphs 11 of this Part. Therefore template 20.5 can have a higher amount as template 43 and the validation rule can't be fulfilled.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3618
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Validation Rules v5014_m and v5015_m for FinRep nGAAP (v2.6)

The definition of EBA Validation rules v5014_m and v5015_m does not work for FinRep nGAAP because template F 04.06 is missing in the formulas. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2017_3527
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Application of SCA when a PSU accesses payment transactions data older than on the last 90 days, without having access to sensitive payment data and for a period of 90 days after the last access using SCA

Could Payment Service Providers (PSPs) be allowed to choose between applying SCA(Strong Customer Authentication) or not when a PSU (Payment Service User) accesses payment transactions data older than on the last 90 days without having access to sensitive payment data and for a period of 90 days after its last access using SCA?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4177
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/11/2018

Persistent authentication for wearable devices

Is persistent authentication for wearable devices compliant with the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4049
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/10/2018

Criteria for the application of the transaction risk analysis (TRA) exemption – Application of the TRA exemption at the level of individual brand, product or scheme

May a PSP calculate its fraud rate at the level of individual brand, product or scheme?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4033
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/10/2018